Object

Representation ID: 9780

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

WDL strongly objects to the omission of their site at 'Land off Old Station Road, Hampton in Arden' (Assessment Site Ref. 6). Site selection methodology has been inconsistently applied and as a result DLPSC has unfairly discounted this site. Evidence within the site assessment document confirms the site to be highly achieving against a number of the matrices, the site performs better than proposed allocations of a similar size and location within settlements of the same Settlement Hierarchy class. Attached appendix A comparison table compares the application of the methodology and associated evidence base in relation to the site (Land off Old Station Road)and comparable sites. It shows a lack of consistency in the justification and associated decision-making set again that same evidence base, resulting in Land off Old Station Road being identified as unsuitable and excluded from further consideration. The sites used for comparison are of similar size and character; having a similar capacity, being wholly or predominantly greenfield, lying within the Green Belt, and lying within a settlement that is within a settlement of the same hierarchy as Hampton in Arden. The table demonstrates that the findings contained with the site assessment document and associated evidence base reinforce that Land off Old Station Road continually performs highly when assessed against the key criteria; including in relation to the spatial vision, site constraints, deliverability, accessibility, impact on Green Belt performance, and sensitivity of landscape character. Significantly, the site adheres to the DLP's spatial vision, reaching a 'Yellow' score of 5 overall in Step 1 of the Site Selection process. Notably, the site scores more favourably than Land South of School Road, Hockley Heath, which is proposed for allocation as DLP Site 25.
Evidence in stage 2 of the site assessment also confirms the site is suitable for development particularly when compared with sites proposed for allocation. Suitability was also demonstrated in the 2016 SHELAA where it was assessed as a category 1 which could commence within 5 years but by comparison the southern parcel of the DLP proposed site 10 was assessed as category 2 and DLP site 6 is identified as category 3 as not currently developable. Site also performs extremely well within the accessibility study. Again findings are inconsistent when compared to other sites. Site also performs to a similar standard or better than comparable sites that have been proposed for allocation within the greenbelt assessment. Despite all of this the site is designated as a red site. Site lies within landscape character parcel which only has medium sensitivity and is more favourable when compared to proposed allocations within Meriden and Hockley Heath. The Sustainability appraisal is also favourable to the site having fewer negative and more positive impacts than other sites proposed for allocation.
The issues of 'indefensible boundaries' and 'visual intrusion' are given a considerable amount of weight in the site assessment process despite the site being assessed favourably in other areas. This is unfounded as this can be readily mitigated and is not permanent. In fact, the advice given by SMBC within the DLPSC (para 75) states that "sites that would use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt" would be considered favourably. It is clear that SMBC have shown inconsistency in the application of site assessment methodology notably this is reflected in the lack of a robust definition for clearly defined boundaries. The DLPSC gives conflicting views on the definition and approach to this, in some instances placing significant emphasis on defensible boundaries as permanent and physical boundaries.